Love is in the air.. Or is it?

With increasing restrictions placed upon our lives due to COVID-19, millions of people have turned to online dating sites to meet someone and spark human interaction. In some instances, it is genuinely love at first sight, but not in others. In such an emotionally charged environment some enter this not for love but for financial gain and tragically, many stumble upon con artists who are eager to take advantage of people looking to make a connection. The fraudster builds up rapport by making up a story and, once they have established enough trust, moves onto the real reason they are there, asking for money. According to UK Finance, there was a 20% increase in bank transfer fraud linked to romance scams in 2019 compared to 2018. However, the damage to the victim often goes much deeper than the financial loss suffered. Navigating relationships can be fraught at the best of times, but here are few things that may help you identify if it is a scammer or not.

Liar liar

Red flags that might help you spot scammers include:

• Asking a lot personal questions about you while avoiding answering personal questions about themselves

• Trying to establish a bond quickly by telling you “this is the first time they’ve felt like this before”, giving you an endearing pet name or even that they are in love with you

• Preferring to move the communication away from dating websites and towards texting or phone calls as the scammers know that the dating website will have no proof of them asking you for money

• Asking for financial help by making up lies (which is covered below)

• never meeting them in person as they are either “out of the country at the moment” or have made up excuses about why they had to cancel - sometimes these include financial reasons

Scammers are inventive when it comes to creating a facade with which to lure victims. Some frequently used lies by scammers in order to request funds include paying:

• For a plane ticket or other travel expenses

• For surgery or other medical expenses

• Customs fees

• Off gambling debts

• For a visa or other official travel documents

Scammers usually request funds via wiring money, putting money on a gift card, or loading money onto a prepaid card. Scammers know that this way, they can get cash quickly and remain anonymous and the transactions are almost impossible to reverse.

Protect yourself

Never send money to a romantic interest you haven’t met in person. If you suspect a romance scam:

• Stop communicating with the person immediately

• Do a search for the type of job the person has to see if other people have heard similar stories. For example, you could do a search for “UK Army scammer”

• Do a reverse image search of the person's profile picture to see if it’s associated with another name or with details that don’t match up

• Contact Action Fraud on 0300 123 2040

If you’d like to learn more, please contact Ishima Romain, consultant or email us at: contact@fintrail.com.

FinTech and Law Enforcement partnerships

Expert Working Group Topic 2: Law Enforcement partnerships

We’ve just wrapped up our second Expert Working Group, following last year’s EWG on FinTech Approaches to Sanctions Regimes. This time, we gathered 16 experts from FinTechs along with law enforcement leaders to chat about our partnerships with law enforcement.

This working group made it clear that finding the right contact or information can be tricky. Please do not hesitate to reach out to the FFE secretariat at ffe_admin@fintrail.co.uk if you need help making contact on an important law enforcement matter—this goes for law enforcement, FIUs and FinTechs. We’re happy to help you find the information you need, quickly.

A sneak peek into just a few of the insights that came from our discussions, which covered FinTech best practices for receiving and responding to requests, SAR feedback, asset freezing, stay-open requests and more: 

• Public/private partnerships and industry groups are tough nuts to crack—58% feel they’ve struggled to get traction with groups that share high-value law enforcement information

• We hear from law enforcement a lot. Half of us receive several requests per week.

• MLROs rarely act as the central point of contact. If you’re an MLRO, and you’re still taking all the phone calls, delegate away—today is your day!

Check out the full report for more, and reach out to us at ffe_admin@fintrail.co.uk to share any insights of your own. And, of course, stay tuned for further Expert Working Groups!

A Year in Review: Financial Crime in the Middle East and Africa in 2020

2020 has clearly been a year like no other.  Both businesses and criminals have had to adapt to the abrupt and far-reaching impacts of the COVID-19 pandemic.  This has drastically accelerated the shift away from cash to digital payments, and encouraged both governments and global actors such as the Financial Action Task Force (FATF) to promote a shift towards digitisation.  The pandemic also provided ample opportunities for criminals to devise new schemes and take advantage of a rapidly changing, uncertain environment.  Many financial institutions in the Middle East, particularly the Gulf Cooperation Council (GCC) struggled with sluggish performance, but most still planned to grow their compliance teams and increase compliance spend over the course of the year, with a focus on technology.  

Below are some of the key financial crime stories and trends from the year across the MEA region:

Fraud and COVID-19

COVID-19 has created opportunities for organised criminals and fraudsters across the globe, and MEA is no exception.  The region has traditionally been dominated by cash payments, but the pandemic accelerated a huge shift to digital transactions (e.g. a PwC survey shows 53% of Middle East respondents making purchases online).  This change, coupled with public anxiety which left people vulnerable to scams, led to a massive increase in fraud including phishing, online shopping fraud, impersonation fraud, and fake charitable appeals. The UAE, for instance, saw a 250% increase last year in cyberattacks, including phishing and ransomware incidents.

Financial institutions need to respond by re-examining their fraud controls, conducting risk assessments to capture the latest threats, and educating their customers on new risks and typologies.  Informal collaboration or industry groups such as the regional charters of the FinTech FinCrime Exchange can be invaluable here.

Spotlight on digital onboarding and eKYC

Regulators in the Middle East and Africa were already moving towards greater digitisation and use of technology to fight financial crime, and this trend has only been accelerated by the COVID-19 pandemic.  In April 2020 the Arab Monetary Fund published a report on ‘Digital Identity and e-KYC Guidelines for the Arab Countries’ to further the debate on adopting digital onboarding tools.  Within the Middle East, the UAE and Bahrain have been the national frontrunners - Bahrain launched an eKYC project mandated by the Central Bank of Bahrain in 2019, to facilitate KYC data sharing amongst participating financial institutions which has continued to develop over the course of 2020, and the UAE introduced its own eKYC platform which went live in July last year.   

As more and more firms look to digitise their compliance processes, against this backdrop of growing official support, care must be taken to select technological solutions which allow firms to reduce any potential risk exposure, and that their use and integration is properly assessed and re-evaluated on an ongoing basis.

FATF Mutual Evaluation Report on the UAE

One major regional news story in 2020 was the publication of FATF’s critical Mutual Evaluation Report on the UAE’s money laundering and terrorist financing controls.  FATF stated the UAE needed to make “fundamental and major improvements” to its AML/CTF systems, and placed it under a year-long observation to ensure that it is properly implementing its recently adopted laws.

The UAE has faced other criticism last year.  It was the only GCC state included in a list of 82 major money laundering jurisdictions identified by the US State Department in March.  A report from the Carnegie Endowment in July on financial crime in Dubai highlighted a number of risk areas and stated that “Dubai’s prosperity is a steady stream of illicit proceeds borne from corruption and crime.”  The investigative and policy organisation The Sentry issued a report in November on how Dubai has become the main destination for illicit gold from Africa.

While the UAE government works to meet FATF requirements over the next 12 months, individual financial institutions need to ensure they have up-to-date risk assessments that reflect the financial crime threats relating to the country highlighted by these external sources, and then align their procedures and controls to address and mitigate the risks.

MEA regulators start to warm up to cryptocurrencies

The growth of cryptocurrency remained relatively low-scale but continued to show promise across both Africa and the Middle East.  Commentators believe the growing level of interest in Africa in particular, and compelling crypto use cases (the instability of fiat currencies and high remittance fees) will force regulators’ hands and encourage the issue of crypto-specific regulations in the near future.  2020 saw the issue of new regulations in Nigeria, South Africa and the UAE, with other jurisdictions such as Kenya and potentially Saudi Arabia likely to follow soon.  The UAE and Bahrain (which issued crypto regulations in early 2019) have both granted licenses to crypto exchanges under the relevant regulations, and currently have a number of crypto companies in their sandbox programmes.

The growing adoption and acceptance of cryptocurrencies in the MEA region will not only require crypto firms themselves to establish robust compliance programmes, but also other companies with potential exposure to them, such as conventional banks.  Crypto is perceived to be a high-risk sector but this does not mean it should be off-limits, and with greater knowledge and training on the associated risks and necessary controls, an increasing number of financial institutions are likely to engage with it in the coming years.

Slow steps towards greater transparency and access to data

Finally, 2020 has seen some positive developments relating to one of the region’s key issues in financial crime compliance, namely transparency and accessibility of data.  A small number of governments have made moves to align themselves with international standards, such as the UAE, Egypt and Kenya, which all introduced new requirements in 2020 for companies to declare their ultimate beneficial owners.  The onus is now on industry bodies to lobby to make all this information public, and on financial institutions to work out how best to integrate these new sources of information into their onboarding, customer risk assessment, and ongoing due diligence processes. Once again, technology is likely to play an increasing role here.

FINTRAIL in 2020

2020 was a key year for FINTRAIL’s coverage of the Middle East and Africa, with the appointment of Maya Braine as managing director, allowing for dedicated coverage and enhancing our understanding and expertise.  We completed several exciting projects with a focus on the region, including an ongoing assignment to provide training to compliance teams across Kenya, Nigeria and South Africa, and the launch of a digital product focusing on the African diaspora.  We also became a Venture Acceleration Partner  of Bahrain FinTech Bay, one of the world’s leading FinTech hubs.  We have ambitious plans for the region in 2021, so watch this space!

If you would like to contact us about any of the topics raised in this article, or about your financial crime compliance needs in the MEA region, please contact maya.braine@fintrail.co.uk. FINTRAIL can assist with performing risk assessments, providing training, implementing RegTech solutions, composing policies and procedures, and designing and reviewing FinCrime controls. For more details on our services, please visit our website.

Inauguration Day: What does the Biden Administration mean for FinCrime?

January 20, 2021. Inauguration Day. The end of an era. Following four years under President Donald Trump, the United States will have a new president. 

What should we expect under the administration of President Joe Biden and Vice President Kamala Harris? Your answer to this question will likely depend on your top priorities. At FINTRAIL, we have been working to help our clients understand and prepare for any and all financial crime-related changes that are anticipated under the new administration. While some specifics are up in the air, it is clear that tackling illicit finance will be a top priority. 

Broadly, we can expect to see some changes from the top down. The new Deputy Treasury Secretary, Adewale Adeyemo, has promised a review of the Office of Terrorism and Financial Intelligence’s programs, including FinCEN, with plans to increase both staffing and budget. With new resources, there is likely to be new guidance and potentially new enforcement measures coming into force. 

Let’s explore in a bit more detail what we are and aren’t likely to see across the major financial crime areas over the next four years:

Money Laundering

At the start of the year, Congress passed the latest National Defense Authorization Act (NDAA), which the Biden Administration will be responsible for implementing. The NDAA outlined several major changes for BSA/AML professionals, particularly the development of a beneficial ownership register. Once implemented, this register will have a huge impact on CDD for legal entities.  Professionals should also keep an eye out for the Biden Administration’s top AML priorities, which must be published within 6 months of the NDAA going into effect, as well as the results of Treasury reviews of existing AML/CTF regulations (especially those around SAR filing) and specific studies on emerging technologies, trade-based money laundering and money laundering to China. While not immediate, these outputs may lead to further significant revisions to the existing AML/CTF landscape.

Compliance changes could also come about through other legislation. For example, with Democrats now in control of both houses of Congress, there is likely to be another push to pass the Safe Banking Act, which would give financial institutions a pass to bank the cannabis industry. This would mean needing to revamp your risk appetite and potentially your screening program, as many firms currently screen against lists of legal cannabis providers that cannot yet be banked under federal law.

Terrorist Financing

Two-thirds of US terrorist attacks in the first eight months of 2020 were from far right wing domestic terrorist groups or individuals, and especially in light of the recent Capitol attack, it is likely that far right wing extremism will remain the most pressing terrorism threat to the United States. This will be a top concern for the Biden Administration, and Biden has promised to pass a new law against domestic terrorism. Even before the recent events at the Capitol, Biden was meeting with advocacy groups, such as the Anti-Defamation League, illustrating a unique commitment and exploration of strategies to counter far-right-wing extremism. Practitioners have struggled with the lack of a specific federal crime for domestic terrorism, and there has not yet been a discussion of exactly what elements of counter-terrorism and counter-extremism the Biden Administration will prioritize. There is more explicit counter-terrorist financing legislation around the financing of foreign terrorist groups, for example, and any changes to laws against domestic terrorism could have knock-on effects for our understanding of terrorist financing. In the short term, some measures within the NDAA can be used to improve counter-terrorist financing efforts, particularly through improved public-private information sharing. 

Bribery and Corruption

Countering corruption at home and abroad is expected to be a central focus of Biden’s overall agenda. Some of the changes made within the NDAA, especially regarding whistleblower protection and requirements around ownership disclosure, directly play into this. However, for many financial institutions, it is unlikely that there will be major changes in day-to-day anti-bribery and corruption exercises, at least in the short term. FinCEN issued an updated statement on PEPs in August 2020, and while further clarification may come along during the Biden administration, there has been no explicit discussion around the position changing in the near future. 

Sanctions Evasion

The Biden Administration has already promised a “top-to-bottom” review of OFAC’s sanctions program. As part of the Obama Administration, Biden did not shy away from the importance of sanctions as a foreign policy tool, so we shouldn’t expect a major shift in their continued use. With that said, there will likely be a shift in the specific regimes applied. Shifts will take time though, especially in light of the recent move to re-add Cuba to the state sponsors of terrorism list and the time that may be needed to renegotiate the Iran nuclear deal. In some areas, we can expect sanctions to tighten. For example, Biden’s Chief of Staff, Ron Klain, has already spoken about the introduction of new sanctions in response to the recent Russian cyber attacks against the US government. There is also emphasis on taking a more multilateral approach to issuing sanctions, which could see the roll back of secondary sanctions or the pursuance of joint US/UK or US/European sanctions targeting human rights violators. Make sure your list provider will be able to quickly and accurately provide you with updated OFAC lists and that you understand any new conditions, particularly if more complex sectoral regimes are applied.

Tax Evasion

President Biden’s pick for National Security Advisor, Jake Sullivan, has previously written about ramping up efforts against tax havens as a core pillar of US trade strategy. Biden has similarly written about the importance of closing tax loopholes and reducing tax avoidance. In the near term, the implementation of the 2021 NDAA will also help with efforts to clamp down on tax evasion, particularly through the targeting of anonymous shell companies. Practitioners should continue to watch this space, as efforts to clamp down on tax avoidance may push some activity that has been licit into being illicit. 

Fraud

Fraud is also likely to be prioritized by the incoming administration, but immediate and wide-ranging changes are unlikely.. In terms of prosecution, experts have noted that there is a “serious backlog” of fraud cases, which will likely take time to process. More practically, BSA/AML professionals should pay attention to when Biden’s new $1.9 trillion COVID relief package is passed - most likely sooner than later given the Democrats’ control of the Senate. This promises further government support for individuals and small businesses, which, like the Paycheck Protection Program, is likely to lead to an increase in related fraud typologies. Make sure your monitoring system is tuned to detect these typologies, especially based on any patterns detected during the prior waves of stimulus, and that you have the human and technical resources to manage any surges in fraud.

Market Manipulation

Experts predict there to be an increase in investigations into market manipulation and securities-related crimes, including insider trading and accounting scams. However, it is important to remember that securities prosecutions can take an especially long time, so we are unlikely to see anything immediate in this space. There has not been a substantial discussion around reforms the Biden Administration is planning, but Gary Gensler, the Administration’s likely pick to head the Securities Exchange Commission, has a history of pushing through stricter oversight regulation and “issuing hefty fines,” as seen during the Libor scandal.

There are going to be changes to the way we think about and operate financial crime programs under the Biden Administration. While it may take some time to see the true impact of these changes, the shift in mindset and priorities will hopefully help the US continue modernising its overall approach to anti-financial crime.

FINTRAIL Monthly REG-CAP Oct 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

October 2020

In October’s issue, we cover FATF’s response to Weapons of Mass Destruction proliferation financing.

Other highlights include the INTERPOL-EUROPOL 8th cybercrime conference and the removal of Sudan from the US sanctions list.

What other regulations changes caught your eye in October?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

FINTRAIL Monthly REG-CAP Sep 2020

FINTRAIL is producing a monthly regulatory summary of any FinCrime changes that may be occurring in Europe and beyond.

This one pager will cover:

1. Key updates from global and local regulators

2. Key updates from industry guidelines

3. Additional insights identified from financial intelligence units

September 2020

In September’s issue we cover FATF’s report identifying red flag indicators of money laundering and terrorist financing through the use of virtual assets.

Other highlights include new UK sanctions issued against Alexander Lukashenko and his associates following election rigging in Belarus, and some interesting new insights from Companies House on additional controls being brought in to help fight fraud and money laundering.

What other regulations changes caught your eye in September?

If you are interested in speaking to the FINTRAIL team about any of the items in the REG-CAP, have any ideas for inclusion or want to discuss any other financial crime topic please get in touch at: contact@fintrail.co.uk

FinTech Approaches to Sanction Regimes

Announcing Expert Working Groups and Topic 1: Sanctions compliance

The FFE have kicked off a series of topical roundtable discussions among industry leaders, with the aim of connecting senior decision makers to discuss their own internal approaches to common challenges. These Expert Working Groups are under Chatham House Rule, with FINTRAIL acting as secretariat to facilitate discussion amongst experts. Thanks to RDC and RUSI, too, for providing expert insights alongside our FinTech experts.

Our first Expert Working Group focused on FinTech approaches to sanctions regimes, and gathered 18 sanctions experts from 8 different FinTech industries. After just two in-depth sessions, we were able to glean insight on best practices that we hope you find useful when benchmarking your own approach. 

As a sneak peek into some of those insights:

• Around 30% of the FinTechs we spoke with have a sanctions-specific risk assessment to support their risk-based approach, with several more working to create one.

• Unanimously, Expert Working Group participants are typically using conservative (or even very conservative) fuzzy matching thresholds ranging from 70%-85%, especially compared to industry averages closer to 85%-92%.  

• C-Suite and board members are increasingly expected to have sight of the Sanctions program and/or Sanctions-specific policies, vs. just the broader Compliance or Anti-Money Laundering program.

Check out the full report for more, and reach out to us at ffe_admin@fintrail.co.uk to share any insights of your own. And be sure to stay tuned for further Expert Working Group insights!

On Demand Webinar: How to Implement eKYC & Keep Online Customers Safe

The recent shift towards digitisation has pushed businesses to review their KYC processes, and implement new strategies to protect their customers online.

In this on demand webinar, Robert Evans Fintrail co-founder and Claire Galbois-Alcaix at Jumio will discuss:

- The impact of digitisation on businesses and their customers
- The latest risks and compliance challenges
- How to implement a successful eKYC
- Tech innovations that help organisations keep their customers engaged
- Changes to the regulatory landscape and the future of eKYC

As people spend more time online, they leave a digital trail of information that can be used against them if put in the wrong hands. The convergence of online and offline has opened up entire new pathways for fraudsters, money launderers, and identity thieves to assume another person’s identity.

KYC (Know Your Customer) refers to the process of verifying the identity of your customers, either before or during the time when they start doing business with your organisation. With eKYC, businesses are able to perform identity verification and due diligence electronically, but must ensure they have the correct end-to-end identity verification strategies in place.

Rob and Claire will share tips and best practices organisations can follow to simplify their eKYC.

FINTRAIL on the Captivated Audience - Season 1, Episode 26

In this episode, FINTRAIL’s James Nurse, joins hosts Sam Sheen and Marie Lundberg on the Captivated Audience podcast.

In this episode James offers insights from recent FINTRAIL papers on Social Media and Financial Crime, and the iterative risk approach to pre and post pandemic working for FinTech.

VIXIO PaymentsCompliance - Payment Firms Scramble To Counter Corona Fraud As Spending Shifts

As warnings abound over the frauds and scams taking advantage of the coronavirus crisis, the flexibility of financial institutions to react and adapt to the emerging threat is being tested.

Gemma Rogers, Co Founder at FINTRAIL was interviewed by Douglas Clarke-Williams, VIXIO PaymentsCompliance about how criminals are using the Covid-19 situation to their advantage to carry out financial crime related activity. Gemma also discusses some of the measures and adaptation an anti-financial team should think about to counter it.

"As you get into the detection methodology, reading up and being aware of these scams, and being aware of how they will manifest, is key," she told VIXIO PaymentsCompliance. "Then you can start to tune your transaction monitoring rules to look for the behaviours which might indicate that a customer has been scammed - or perhaps, worst case scenario, that a customer is perpetrating one of these scams."

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The Role of Social Media in Furthering Financial Crime

Content warning: discussion of topics linked to suicide and child exploitation

Recently in the UK we’ve seen the suicide of a reality TV presenter, and in March 2019, the father of Molly Russell urged the government to introduce regulation on social media platforms in response to his 14-year-old daughter taking her own life. She was found to have viewed content related to depression and suicide on Instagram before her death.  While neither of these tragic instances can be solely attributed to social media, many are discussing the arguably significant role that online media played in both cases.  

Following on from these instances, in early 2020 the government announced that Ofcom - the communications regulator - was to be given the power to fine social media companies in a bid to protect children from harmful online content. Ofcom will not only be able to fine companies that fail to remove illegal content - such as the promotion of terrorism or child pornography - but online platforms will also be required to stipulate what behaviour and content is acceptable on their sites, and enforce those rules consistently and transparently. 

Clearly, the priority for Ofcom and social media firms has to be removing the most immediately harmful content - that which promotes suicide and child exploitation being critical.  However, there is also an argument for Ofcom and the social media firms to ensure that other types of content are correctly classified as illegal and are therefore removed. The other types of content that we at FINTRAIL believed should be more heavily moderated and removed pertains to financial crime.  

From our consulting experience in the FinTech sector, we have seen a multitude of financial crime cases where the schemes start on social media. In fact many of the low level criminal activities are facilitated and can only be effective due to social media.  A few examples include:

• Promoting the sale of goods on social media platforms; victims agree to purchase the goods, transfer the money to an account (often in the scammer’s own name, using their real identity) and the goods never materialise.  These are also known as advanced fee fraud.

• Money launderers recruit people - and pay them for access to their bank accounts - via social media profiles.  The launderers use the access to the recruits’ accounts to wash the proceeds of crime. This is known as money muling, and is worryingly common, even among young people.  

• Scammers can further advertise purported investments schemes online, attracting potentially thousands of users and defrauding them of large sums of money, sometimes even their life savings.

Images from social media used to entice individuals into money muling and other get rich quick scams.

Even in isolation, the results of these scams and schemes are incredibly harmful to the individuals involved; in some cases causing them to be blacklisted from banks (for having perpetrated money laundering through their accounts in the case of money mules), or in others to lose significant amounts of money.  However, it is also important to recognise the wider harm that such behaviour has on the rest of society.

Firstly, not only do many of the fraud and laundering schemes detailed above connect back into wider organised crime, involving the predicate offences of illegal drugs sales, human trafficking, corruption, arms trafficking, kidnapping and extortion (inter alia), all of which have an enormous human cost; secondly, the estimated cost of financial crime to global economy is conservatively estimated at between USD 1.6 trillion and USD 2.2 trillion. A Global Financial Integrity report from 2017 underscores how transnational crime undermines economies, societies, and governments, particularly in developing countries, often preventing those who are most vulnerable from getting the support they need, ironically, increasing the chances that they too become embroiled in a life of crime.

So, it’s with these huge human, societal and economic costs in mind that Ofcom needs to work closely not only with the social media firms themselves, but also with financial services firms, financial services regulators and law enforcement to best determine what content should be categorised as illegal and harmful, and seek to include this in their regulatory scope.  

In the same way that financial services firms are heavily regulated - because of the harm the provision of their services can cause - social media firms should also be required to take more proactive steps to prevent, deter and detect illegal and harmful content pertaining to financial crime from appearing on their sites.  

Practical steps social media firms can take mimic those applied in the financial services sector, such as Knowing Your Customer (KYC) processes  - including identity verification such that they can more effectively block repeat offenders - and more intelligent activity (transaction) monitoring, such that they can proactively identify higher risk profiles that should be subject to enhanced monitoring. This doesn’t have to be an arduous process: the FinTech sector has demonstrated that frictionless processes can exist, whilst maintaining compliance and gathering an appropriate level of customer due diligence in the process.

Clearly, any of these processes will have to be implemented proportionately, particularly to ensure the continued freedom of expression and speech.  However, considering the harm that social media appears to be, if not causing then at least amplifying, spending time, effort and money combating these issues and working to ensure proportionality is key for the ongoing success and safe utilisation of social media platforms in today’s society.

Get in Touch
If you are interested in speaking to the FINTRAIL team about the topics discussed here or any other anti-financial crime topics in an increasingly digital FinTech world, please feel free to get in touch with one of our team or at contact@fintrail.co.uk